If you manage assets for clients in Switzerland, on a discretionary mandate, you need a licence from FINMA. Since the Financial Institutions Act came into force in 2020, the independent asset manager who worked with an SRO membership alone no longer exists.
Who needs it
Anyone who, on a commercial basis, manages assets in the name and for the account of clients, with the power to decide on investments. If you only give advice and the client decides, you are not a portfolio manager, but you may have to register as a client adviser.
The main requirements
- A Swiss company with its registered office and actual management in Switzerland.
- Minimum share capital of CHF 100,000, fully paid up, plus own funds in proportion to your fixed costs.
- Management by qualified people: as a rule at least two, with proven experience in managing third-party assets and the required training. A one-person structure is possible only in limited cases.
- Risk management and internal control, which can be outsourced to a qualified provider but cannot be ignored.
- Persons who are fit and proper, and shareholders with a qualifying holding who are of good reputation.
- Affiliation to a supervisory organisation, and to an ombudsman office for client disputes.
How the process works
You first sign up with a supervisory organisation, which must confirm it is willing to supervise you. You then file the application with FINMA through its platform. FINMA reviews, asks questions, and grants the licence. Afterwards, the supervisory organisation supervises you and an audit firm audits you.
Timeline and cost
A well-prepared file goes much faster than a rushed one. Most of the delay comes from questions on the organisation, the people and the business plan, not from the forms. Budget for the set-up, the supervisory organisation’s fees, the audit, the ombudsman, the compliance and risk functions, and the capital you must keep in the company.
What nobody tells you
The licence is granted to a structure, not to a star manager. If your organisation depends on one person, FINMA will ask what happens if that person is ill, leaves or dies. Have the answer in the file before the question comes.
And the licence is only the start. The bank that holds your clients’ assets will do its own due diligence on you, and some custodian banks have minimum asset thresholds for working with independent managers.
Planning to apply for a portfolio manager licence, or to buy a licensed company instead? Contact FintechLex · insight@fintechlex.com
Last updated: October 2026. This article is general information, not legal advice.
